S. 201(3) as amended by Finance (No. 2) Act, 2014, with effect from 1-10-2014 provides for limit for passing order to be within seven years from end of financial year in which payment was made or credit was given and for earlier years said limitation period would be two years from end of year in which payment was made. ( AY.2009-10)
Vodafone Cellular Ltd. v. DCIT (2018) 169 ITD 675 (Pune) (Trib.)
S. 201 : Deduction at source – Failure to deduct or pay -Limitation of two years prior to amendment , by Finance (No. 2) Act, 2014, with effect from 1-10-2014 and seven years thereafter [ S. 201(3) ]